ML20211K943
| ML20211K943 | |
| Person / Time | |
|---|---|
| Site: | Oconee, Mcguire, McGuire  |
| Issue date: | 09/26/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20211K917 | List: |
| References | |
| 50-369-97-13, 50-370-97-13, NUDOCS 9710100072 | |
| Download: ML20211K943 (29) | |
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NOTICE OF VIOLATION Duke Energy Corporation Dc N t Nos. 50 369, 50 370 McGuire Units 1 and 2 Licerse Nos. NPF 9 NPF 17 EA 97 411 During an NRC Inspection conducted on July 21 through 24, 1997, violations of NRC requirements were identi' Tied.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions." (NUREG 1600) the violations are listed below:
A.
Technical Specification 6.8, requires, in part, that written procedures shall be established, implemented and maintained for ap procedures in Appendix A to Regulatory Guide 1.33 Rev.plicable i
2, 1978.
Appendix A specifies procedures for Security and Visitor Control, McGuire Procedure Nuclear System Directiw 218 of Nuclear Policy Manual-l Volume 2, requires management, in the case of involuntary and voluntary termination, to be responsible for verbally notifying, site security and/or site staffing contacts to delete the individuals' security badge.
For involuntary terminations, security is to be notified prior to the termination / discharge or simultaneously with the termination / discharge.
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Security Procedure EXAO 02, Security Badge Program, Rev. 62.
Paragraph III.B.8.c. provides that if termination is unfavorable, Security shall be contacted.
Contrary to the above, the licensee failed to follow procedures for security badge and access control as evidenced by the following:
1.
On April 8,1997, two individuals were terminated, one involuntarily (unfavorable), and the responsible manager failed to notify security prior to or simultaneously with the terminations.
As a result the terminated individuals, with protected and vital areaaccess,gainedaccesstotheprotectedareaandcouldhave accessed vitai areas.
2.
On April 19, 1996, a vendor failed to notify security of the involuntary (unfavorable) termination of three individuals with protected and vital area access. There was no access to the protected or vital areas after their termination.
3.
On July 2,1997, a vendor failed to notify security of the involuntary (unfavorable) termination of an individual with protected and vital area access. There was no access to the protected or vital areas after termination.
4.
On July 8,1997, a vendor failed to notify security of a voluntary (favorable) termination of an individual with protected area access.
No protected areas were accessed.
(01013)
DR DOC 05 0 69 G
B.
-Technical Specification 6.8, requires, in part, that written procedures shall be established, implemented and maintained for applicable procedures in Appendix A to Regulatory Guide 1.33. Rev. 2, 1978.
Appendix A specifies procedures for Security and Visitor Control.
l Security (Procedure EXAO 02, Security Badge Progr6m, Rev. 62. paragraph III.B.8e 2) provides that security bad l
when security is informed of a person'ges shall be removed from storage I
s termination.
Contrar to the above, the licensee failed to follow procedures for securit badge and access control as follows:
1, On January 30, 1997,. security failed to remove-the access badge from storage in the badge rack following notification of the voluntary (favorable) terminated of_ an individual who had protected and vital area access authorization. No protected or
-vital areas were accessed.
2.
On June 30, 1997, security failed to remove the access badge of an individual from storage in the badge rack following notification (via the Daily Deletion Report) of the ex individual's 180 day temporary clearance.piration of the As a result on July 3, 7 and 8,1997, the individual, with protected area access only, entered the protected area.
(01023)
These violations represent a Severity Level III problem (Supplement III).
C.
The McGuire Facility Operating License NPF 17, Part 2.E, states, in part, that the licensee shall fully implement and maintain in effect all provisions of the Commission approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements,- revisions to 10 CFR 73.55, and to the authority of 10 CFR 50.90 and 10 CFR 50,54(p).
Duke Power Company Nuclear Security and Contingency Plan, Rev. 6 dated May 13, 1997. Chapter 6. " Access", Paragraph 6.3, provides that
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protected area badges shall remain within the protected area.
Security Procedure EXA0 2, Security Badge Program, Rev 62, paragraph III.B.S.c provides that prior to exiting the protected area, all badges shall be returned to the exit turnstile at the primary access portal.
Contrary to the above, the. licensee failed to follow Security Procedure EXAO 2 on ten occasions between the dates of February 5, 1997 and r
July 10,1997, when the licensee failed to contral protected area access badges, and the badges were.taken outside the protected area.
(02014)
This is a Severity Level IV violation (Supplement III).
l Pursubnt to the provisions of 10 CFR 2.201, Duke Energy Corporation is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,-Washington, D.C. 20555 with a copy to the Region 61 Administrator, Region II, and a copy to the NRC L
Resident Inspector at the McGuire facility, within 30 days of the date of the letter transmitting this.Nc M ce of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation:
(1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved. (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.
Your response may reference or include previously docketed correspondence, if the correspondence adequately addresses the recuired res)onse.
If an adeauate reply is not received within the time specifiec in this 40tice, an order or a Demand for Informatien may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be aroper should not be taken. Where good cause is shown, consideration will se given to extending the response time.
Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
Because your res)onse will be placed in the NRC Public Document Room (PDR), to-the extent possiale, it should not include any personal privacy, 3roprietary, or safeguards information so that it can be placed in the PDR wit 1out redaction.
If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and e redacted copy of;your response that deletes such information.
If you request withholding of such material, you must saecifically identify the portions of your response that you seek to have withleld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information).
If safeguards information
.is necessary to provide an accepteble response, please provide the level of protection described in 10 CFR 73.21.
Dated at Atlanta, Georgia this-26th day of September 1997
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e LIST OF ATTENDEES QukeEneravCorocration H;'Barron, Site Vice President, McGuire Nuclear Station R. Birmingham, Manager Human Resources H -Cash, Manager, Regulatory Compliance
.W. Evans, Manager Station Security E. Sellers, Technical Specialist, Security Staff R. Sipe, McGuire Community Relations Manager L. Reyes.- Regional Administrator-B. Uryc, Director, Enforcement and Investigations Coordination Staff-(EICS)
C Evans, Regional Counsel Ji Jaudon, Director, Division of Reactor Safety (DRS)
J. Johnson, Director, Division of Reactor Projects (DRP)
H. Berkow, Director, Project-Directorate 112, Office of Nuclear Reactor Regulation (NRR)
V. Nerses, Project Manager, NRR C. Julian, Acting Ch1ef Special Inspection Branch, DRS R.-. Carroll, Project Engineer, DRP-K. Clark, Senior Public Affairs Officer
.L._ Watson, Enforcement Specialist, EICS W. Stansberry, Safeguards Inspector, DRS S. Rohrer, Radiation Specialist, DRS
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ENFORCEMENT CONFERENCE AGENDA McGUIRE NUCLEAR STATION SEPTEMBER 19, 1997, AT 10:00 A.M.
NRC REGION II 0FFICE, ATLANTA, GEORGIA
'I.
OPENING REMARKS AND INTRODUCTIONS i
L. Reyes Regional Administrator II.
NRC ENFORCEMENT POLICY B. Uryc Director Enforcement and Investigation Coordination Staff III.
SUMMARY
OF THE ISSUES L
Reyes Regional Administrator IV.
STATEMENT OF CONCERNS / APPARENT VIOLATIONS J. Jaudon. Director Division of Reactor Safety V.
LICENSEE PRESENTATION VI BREAK / NRC CAUCUS VII.
NRC FOLLOWUP QUESTIONS VIII CLOSING REMARKS L
Reyes Regional Administrator
E ISSUES TO BE DISCUSSED JSSUE A Technical Specification 6.8
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Nuclear Policy Manual-Volume 2.
Nuclear System e-Directive 218 Security Procedure EXAO-02 e
1.
On April 8,1997, an individual was involuntary (unfavorable) terminated and the responsible manag'er failed to notify security prior to or simultaneously with the termination.
As a result the terminated individual, with protected and vital area access gained access to the protected area and could have accessed vital areas.
2.
On April 19,
- 1996, a
vendor failed to notify security of the involuntary (unfavorable) termination of three individuals.
There was no i
access to the protected area after thei r termination.
3.
On July 2,
- 1997, a
vendor failed to notify
. security of the involuntary (unfavorable) termination of an indi vidual.
There was tio access to the protected area after termination.
4.
On July 8.
- 1997, a
vendor failed to notify security of:a voluntary (favorable) termination of an individual No protected areas were accessed.
NOTE: The apparent violation discussed in this i
predecisional enforcement conference is subject to further review and is subject to change prior to any resulting enforcement action.
N%V "
ISSUE B Technical Specification 6.8 e
Security Procedure EXAO-02 e-1.
On January 30, 1997, security failed to delete a voluntary (favorable) terminated individual's protected areas access badge.
In addition,
during the months of February March. April and May
- 1997, a
vendor failed to recognize the nondeleted badge and notify security during a 31 Day Badge Review of badging status.
No protected areas were accessed.
2.
On April 11, 1997, security failed to delete a voluntary (favorable) terminated individual 's protected areas access badge l
3.
On June 30, 1997, security failed to terminate access of an individual when his 180 day temporary clearance expired.
As a result on July 3, 7 and 8,1997, the terminated individual with protected area access only, entered the protected area NOTE: The apJarent violation discussed in this predecisional enforcement conference is subject to further review and is subject to change prior to any resulting enforcement action.
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ISSUE C Security Procedures EXAO-2 e
On ten occasions between the dates of February 5,1997 and July 10
- 1997, the licensee failed to control protected area access badges, in that the badge were taken outside the protected area unescorted by security personnel.
NOTE: The apparent violation discussed in this predecisional enforcement conference is subject to further review and is subject to change prior to any resulting enforcement action.
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4 LICENSEE PRESENTATION MATERIAL
CGul o ]if PRE-DECISIONAL ENFORCEMKST COXFERENCE September 19,1997
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cGuire' VN BADGES AVAILABLE AFTER TERMINATION
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Badges Available After Termination l
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In 5 of the 7 occurrences, vendor supervisors were involved.
In 2 of the 7 occurrences, Security Officers were involved.
All badging occurrences were selfidentified and corrective actions were implemented in a timely manner.
From 1st Quarter 1996 through year to date 1997, Security has processed 4,294 badge terminations with 7 occurrences.
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Badge Termination vs Reportable Occurrence O
-- Badge Termination
- - Reportable Occurrence 1200 -
Totah 4,294 1000- 792 800 685 600 -
400 -
246 200 -
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0 0
1 3
2 7, -
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e 1st 2nd 3rd 4th 1st 2nd 3rd Qtr Qtr Qtr Qtr Qtr Qtr Qtr 1996 1997
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4 BADGE AVAILABLE AFTER TERMINATION OCCURRENCE #1 (A1)
PIP: 0-M97-1481 s
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..- -.._i Occurrence Date: 4/8/97 A Sunstates vendor employee was terminated for poor performance.
At the same time, another Sunstates vendor employee resigned.
It took 15 minutes from the time of termination for the vendor supervisor to notify Security to delete the badges.
Both individuals had protected area and vital area access authorization.
Both individuals entered the protected area to clean out their lockers but access was not gained to the vital areas.
Both individuals were in the protected area a total of 9 minutes.
Security located the individuals within 2 minutes after notification and es arted them out.
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BADGE AVAILABLE AFTER TERMINATION OCCLRRENCE #2 (A2?
PIP: 0-M97-1056 g-
___y Occurrence Date: 4/19/96 Three Atlantic Group employees terminated for cause on 4/19/96.
All three individuals had protected area and vital area access authorization.
The badges remained active for approximately four hours following the individuals' termination.
Access was not gained to either the protected or vital areas of the station.
\\%1h5F1 ERG'BonnieTresentation~Enfortement Confererresecurity Enf. ppt
1 BADGE AVAILABLE AFTER TERMINATION OCCURRENCE #3 (A3)
PIP: 0-M97-2584 n
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__.x Occurrence Date: 7/2/97 An Atlantic Group vendor employee was terminated for a positive random drug test on 7/2/97.
Atlantic Group supervisor did not notify Security to delete the badge until 7/3/97.
The individual had protected area and vital area access authorization.
Access was not gained to either the protected or vital areas of the station.
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BADGE AVAILABLE AFTER TERMINATION
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OCCERREXCE #4 (A4)
PIP: 0-M97-2820
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Occurrence Date: 7/8/97 A Sunstates vendor employee favorably terminated on 7/8/97.
i The Sunstates vendor supervisor failed to notify Security to delete l
the badge.
Security placed the badge on "no access hold" 10 days later.
j rhe individual had protected area access authorization only.
l The badge was terminated on 7/24/97.
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Access was not gained to the protected area of the station.
l The vendor supervisor is no longer at MNS.
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BADGE AVAILABLE AFTER TERMINATION OCCURRENCE #5 (B1)
PIP: 0-M97-2246
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s-Occurrence Date: 1/30/97 i
A Bartlett vendor employee was favorably terminated on 1/30/97.
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The badge was placed on "no access hold" 10 days later.
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The individual had protected area and vital area access authorization.
l Access was not gained to either protected or vital areas of the station.
l The Bartlett vendor supervisor said he notified Security to delete the badge 30 minutes prior to tha termination.
i The Duke Power Badging Sponsor failed to recognize the non-a deleted badge on four successive 31 day reviews.
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BADGE AVAILABLE AFTER TERMINATION 1
OCCLRRENCE #6 (B2)
PIP: 0-M97-1541 c.
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.. a Occurrence Date: 4/11/97 Security was notified of a favorable termination of a Duke Power temporary employee in a timely manner.
The individual had protected area and vital area access authorization.
Security immediately deleted access authorization in the security computer which restricted the individual's access to the station.
The badge remained in the badge drawer for 2 days before discovered in a routine 7 day badge inventory.
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BADGE AVAILABLE AFTER TERMINATION
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OCCURRENCE #7 (B3)
PIP: 0-M97-2617
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Occurrence Date: 6/30/97 A Security Officer failed to ptdl the badge of a Radco vendor employee on 6/30/97 after the vendor's temporary 180 days clearance expired.
The vendor employee accessed the protected area on 7/3/97,7/7/97, and. 7/8/97.
The individual had protected area access authorization only, no vital area access was gained.
The badge remained available for issuance until 7/8/97.
The vendor employee received permanent clearance on 7/17/97.
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SCMMARY CAUSES/ CORRECTIVE ACTIONS
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OCCURRENCE CAUSE CORRECTIVE ACTIONS t
- 1. S unstates S upervisor inadequate Training Counseled and retrained l
- 2. A tlantic S upervisor Inadequate Training Counseled and retrained
- 3. A tlantic Supervisor Failure to Follow Counseled. Supervisor understands another P ro c e d u re s occurrence may lead to termination
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- 4. Sunstates Supervisor Failure to Follow No longer at M NS i
P ro ced u re Site Wide Communication for all Duke Supervisors
- 5. B artlett S upervisor Unknown Established termination process to include a i
dedicated phone line i
- 6. Security O fficer Failure to Follow Counseled and retrained P ro ce d u re R etrained all P A P Control O fficers Implemented H uman Error Reduction training
- 7. Security O fficer H um an Error Counseled and retrained Increased frequency of checking the Daily Deletion i
Report j
Deleted clearance remains on Daily Deletion Report i
until acknowledged
[
. Implemented process to check temporary badges prior to their 180 day expiration i
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Summary Continued e
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Given 5 occurrences involving vendor supervisors, 1
additional corrective actions will be taken.
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- All vendor supervisors and badging sponsors will be retrained by 10/15/97. New vendor supervisors trained during outage I
orientation.
- As mentioned earlier, we will perform an assessment of the 31 l
day review by 11/1/97 to determine its overall effectiveness.
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- McGuire' l
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CONTROL OF PROTECTED AREA BADGES
%t4F1 ERC'3cnaieheserdation Enforcer rnt ConfervrreSectaity Enf.gd
- 10 occurrences in 1997 YTD of badges exiting the i
protected area. Overall cause - Inattention to Detail l
There were other contributing factors:
1 - ADT Monitor equipment failure f
5 - Damaged ADT Coils a
1 - Protected Area Access Only badge - No coil i
2 - Badges masked by equipment or clothing 1 - Poor location.of a compensatory Security Officer j
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1997 YTD,340,622 badged employees exited e
the ;protectec. area.
- Considering 340,622 exits and 10 occurrences our human error failure rate is.00002%
- We estimate the ADT equipment alarms approximately 300 times per year. Based on the 10 occm:rences, we estimate the ADT equipm.ent reliability to be 97%.
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Security Equipment Availability 1997 ru xx__.2.c_:
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... _ : a Intrusion Detector System:
100 %
Closed Circuit TVs:
100 %
Metal Detectors:
99.2 %
Explosive Detectors:
98.5 %
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t SLMMARY CALSES/ CORRECTIVE ACTIONS
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OCCURRENCE CAUSE CORRECTIVE ACTIONS 10 Inattention to detail
. Site Wide Communication from Brew Barron on importance of Badge Control.
. Posted Security Officer at each PAP exit.
. After each occurrence, equipnrnt was tested
.(coils and monitors).
. Adjusted sensitivity / location of monitors.
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. Ihe new access control system (palm geonrtry) l will be implenrnted in mid 1998 and will eliminate future occurrences.
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NMNiF1 ERG %nnieTnwnfation'Enferrenrnt Cenfen n:eBecurity Enf.;7t t
'"2""4f SEMMARY
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g Beyond the corrective actions discussed today, and on a broader basis, we are continuing to improve the overall effectiveness of our Security Program.
- Replaced Security Manager.
- Implemented a Human Error Reduction Program in 1997.
Implemented a continuous improvement plan in January 1997 which focuses on measures, self assessments, and process improvements.
- Implemented a performance based internal audit program in August 1997 which monitors task proficiency of our Security team.
- We continue to benchmark with nuclear security organizations around the country to identify best practices.
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